GLE Middle East - Legal Intelligence

27 August 2026 | Read online

The Legal Developments Shaping Your Region This Fortnight

Good morning from the GLE Editorial desk. This fortnight the region redrew the plumbing of how business is actually done. The UAE suspended all trade, commercial exchange and financial transactions with Iran, with no end date attached, which turns contract performance and banking exposure into an immediate question for a very large number of businesses. Kuwait approved specialist economic courts with published judgments and a stated route to enforcing foreign judgments. Abu Dhabi permissioned a global operator for tokenised securities. The UAE put every venue that plays music on a licence from December without publishing the fees. Oman made electronic invoicing mandatory and, in the same decision, stopped paper and PDF invoices counting at all. For counsel advising on Gulf exposure, the common thread is that the operational detail is where the legal risk now sits.

Joel Gordon, Editorial · Global Law Experts

Quick digest

The UAE Ministry of Foreign Affairs suspended all trade, commercial exchange and financial transactions with Iran on 18 August, until further notice and with no end date given.

Kuwait's cabinet approved a law establishing specialist economic courts on 18 August, with an electronic platform of published judgments and units dedicated to enforcing foreign judgments.

The ADGM Financial Services Regulatory Authority granted Coinbase a Financial Services Permission, with Abu Dhabi established as its tokenisation hub.

From December, restaurants, hotels, malls, fitness centres and airlines across the UAE need a licence for commercial music use under Ministerial Resolution No. 136 of 2026, with fee brackets unpublished.

Oman's Decision No. 189/2026 makes e-invoicing mandatory from April 2027 for larger businesses and October 2027 for the rest, and paper and PDF invoices will no longer qualify as tax invoices.

Jurisdictions covered

United Arab Emirates · Kuwait · Oman · Saudi Arabia · Israel · Lebanon · Libya

Lawyers featured in this edition

Paulina Schulte · Jem Felicilda · Idan Levy · Abdulrahman Garoub · Dr. Bini Saroj · Jakob Kisser · Elena Sadovskaya

What mattered this fortnight

United Arab Emirates · Trade and Sanctions

The UAE Suspends All Trade and Financial Transactions With Iran, With No End Date, 18 August

The Ministry of Foreign Affairs announced that all trade, commercial exchanges and financial transactions with Iran are suspended until further notice. Afra Al Hameli, Director of the Strategic Communications Department, said the measures follow regional escalations threatening regional and international peace and security.

Why it matters for counsel: Al Hameli reaffirmed the UAE's commitment to safeguarding the integrity of the international financial system and to complying with international law and global standards. The UAE has been the principal re-export route into Iran for decades, so an open-ended suspension is not a diplomatic gesture, it is an immediate contract-performance, banking and licensing problem for a very large number of UAE-based businesses. The absence of any end date is what makes it legally difficult: force majeure and frustration analysis turns on duration, and there is currently no duration to analyse.

“First, map the full Iran exposure, not just contracts, but counterparties, beneficial ownership, banks and payment routes, then determine what must stop and which contractual protections are triggered.”

Jakob Kisser · Kisser Legal · United Arab Emirates

Kuwait · Courts and Enforcement

Kuwait's Cabinet Approves Specialist Economic Courts With Published Judgments, 18 August

The cabinet approved the law on Tuesday 18 August. It creates specialist court divisions for commercial and financial disputes, an electronic platform carrying a database of published judgments and judicial principles, expanded electronic litigation, and specialised units to enforce judgments issued by foreign courts outside Kuwait.

Why it matters for counsel: Justice minister Nasser Al-Sumait called it a qualitative leap in the economic justice system. The two features that matter to foreign counsel are precisely the ones that have always required a caveat in Kuwaiti advice: a searchable body of published judgments, and a stated institutional route for enforcing foreign judgments. It arrives inside a wider enforcement drive that has already closed more than 73,000 companies and suspended new freelance business licences, with removal from the FATF grey list as the objective.

United Arab Emirates · Financial Services

Abu Dhabi Permissions Coinbase for Tokenised Securities and Becomes Its Tokenisation Hub

The ADGM Financial Services Regulatory Authority granted a Financial Services Permission, with Coinbase establishing its tokenisation hub in Abu Dhabi. Wallet-based stock trading is permitted, with redemption routed through a broker.

Why it matters for counsel: Tokenised securities have been a consultation topic across the Gulf for two years without a flagship permission to point at. This is a named global operator actually permissioned in a Gulf jurisdiction, which gives competitors and their counsel a template to be measured against and gives ADGM a first-mover position it will defend. The structural detail worth watching is the broker-intermediated redemption, which is where the regulatory perimeter between a token and a security is actually being drawn.

“In practice, Coinbase approval sets the template for future applicants rather than the minimum bar. Smaller firms can build equivalent structures, provided their governance, custody, and investor protection are genuinely robust.”

Elena Sadovskaya · Inteliumlaw · United Arab Emirates

United Arab Emirates · Intellectual Property

Every UAE Venue That Plays Music Needs a Licence From December, and the Fees Are Not Published

The Ministry of Economy and Tourism launched the Collective Management Guide for Music under Ministerial Resolution No. 136 of 2026, announced on Tuesday 11 August. From the start of December, restaurants, cafes, hotels, floating hotels, shopping malls, fitness centres, airlines, radio stations, television channels and concerts all need a licence for commercial music use.

Why it matters for counsel: Fee brackets vary by the nature of the use and the size of the economic activity, and the Ministry did not publish individual amounts, so thousands of hospitality and retail operators have roughly three months to size an exposure that is not yet knowable. Licences run for one year and are renewable, with the Emirates Music Rights Association and Music Nation permitted to collect and distribute. Educational institutions, government entities, national occasions and non-commercial personal events are exempt. Ten per cent of everything collected goes to a new Cultural Support Fund for Music, and the Ministry takes field inspection powers over the collecting bodies.

Oman · Tax and Compliance

Oman Makes E-Invoicing Mandatory and Stops Paper and PDF Invoices Counting at All

The Tax Authority issued Decision No. 189/2026, amending the Executive Regulation of the VAT Law to require electronic invoicing for VAT-registered businesses. Companies with annual supplies above OMR 5 million come under it from 1 April 2027, and those below from 1 October 2027.

Why it matters for counsel: Invoices must be generated in XML through a system connected to an accredited e-invoicing service provider and exchanged between sellers' and buyers' systems with little or no manual intervention. The line that will surprise finance teams is that paper invoices, PDF invoices and emailed digital images of invoices will no longer qualify as electronic tax invoices once the amendments take effect. Idris bin Hamoud Al Rashdi, Director of the Electronic Invoicing Project, framed it as strengthening compliance and transparency. A voluntary pilot of 100 companies begins at the end of August, and choosing an accredited provider is a procurement decision that has to be made well before either deadline.

Gulf States

Saudi Arabia · Transport

Ninety-Day Limit Imposed on GCC-Registered Vehicles, with Fines up to SR2,000

Announced 22 August. Businesses running cross-border fleets into the Kingdom on GCC plates now face a hard duration limit and a penalty for overstaying it. Logistics and fleet operators should track vehicle entry dates and plan re-registration before the ninety days expire.

United Arab Emirates · Immigration

Dependant Sponsorship Extended to Age 25, and a Residency Route Opened After Bereavement or Divorce

Announced across 16 to 20 August. Foreign residents can now sponsor children until 25, and foreign women widowed or divorced from Emirati husbands gain a residency path. Employers should tell affected staff, since dependant status changes usually surface through HR before they reach legal.

Levant

Lebanon · Banking and Finance

Parliament Passes the Bank Resolution Amendments the IMF Asked For

The higher banking commission inside the Central Bank is reconstituted and empowered to decide whether a bank is restructured, liquidated or rehabilitated. It still needs presidential approval, and members may challenge it before the constitutional council. Creditors and depositors should watch the constitutional challenge, since it determines when the regime actually bites.

Lebanon · Banking and Finance

The Depositor Recovery Law Remains Under Negotiation with the IMF

The draft Financial Stabilisation and Depositor Recovery law is still being aligned with international principles. It is the half of the depositor question the resolution law does not answer. Depositors and their advisers should treat recovery planning as unresolved until this second law is settled.

North Africa

Libya · Arbitration

A Benghazi Court Voids the Al-Kharafi Arbitration Award Within and Outside Libya, and Reverses It

In a ruling publicised on 20 August, the North Benghazi Court terminated the 2006 tourism land lease, declared the March 2013 award null and void in its entirety and not recognised within or outside Libya, and ordered the company to pay the Libyan state 15 billion dinars. The 2013 award had obliged Libya to pay US$936.94 million. Award holders with Libyan exposure should take enforcement advice jurisdiction by jurisdiction.

Libya · Disputes

Libyan Investment Authority Seeks Disclosure Over a Suspect 50 Million Dollar Investment

Reported 12 August. The sovereign fund continues to pursue historic placements through foreign courts, a second front alongside the Al-Kharafi litigation. Funds and intermediaries that handled Libyan sovereign money should expect disclosure requests to continue across multiple jurisdictions.

Member spotlight

Paulina Schulte

Knightsbridge Group · United Arab Emirates · Company Formations

Senior client advisor at Knightsbridge Group, working with entrepreneurs, investors and families on cross-border structuring, asset protection, legacy planning and global mobility. She has lived and worked in Poland, Spain and the United Arab Emirates.

Read their GLE profile

Jem Felicilda

Knightsbridge Group · United Arab Emirates · Citizenship and Residency

Advises high-net-worth individuals, entrepreneurs and global families at Knightsbridge Group on United Arab Emirates residency and Golden Visa routes, citizenship and residency by investment, and cross-border relocation planning.

Read their GLE profile

Idan Levy

MITIGATE Compliance & Risk Management · Israel · Compliance

Founder and chief executive of MITIGATE Compliance and Risk Management, with more than twenty years in financial services compliance including senior roles at major banks. He established Israel's first compliance officer training programme and founded the Israeli Compliance Community.

Read their GLE profile

Abdulrahman Garoub

The Law Firm Of Majed Mohammed Garoub · Saudi Arabia · Sports

Practises sports and entertainment law at The Law Firm of Majed Mohammed Garoub, established in 1995 and with a Riyadh branch since 2000, advising on the legal questions specific to Saudi Arabia's sports and entertainment sectors.

Read their GLE profile

Dr. Bini Saroj

Khalifa Bin Huwaidan Alketbi Advocates & Legal Consultants · United Arab Emirates · Construction

Partner and head of litigation and alternative dispute resolution at Khalifa Bin Huwaidan Alketbi Advocates in Abu Dhabi, with twenty years of practice in the United Arab Emirates across construction, banking, real estate, corporate restructuring and insurance.

Read their GLE profile

What we're tracking next

United Arab Emirates: whether the Iran suspension is given an end date, a licensing carve-out, or guidance on existing contracts.

Oman, 1 April and 1 October 2027: the two e-invoicing compliance dates, with the 100-company pilot reporting first.

United Arab Emirates, December 2026: music licensing fees begin, and the fee brackets have still not been published.

Open calls for commentary

We are building the next Middle East edition now and would welcome a short attributed view on any of the following. Reply to this email with two or three sentences and we will run it with your name, firm and country. United Arab Emirates: with no end date on the Iran suspension, is this force majeure or frustration, and what should a contract review prioritise? Oman: what does a company need to establish about an e-invoicing service provider before it signs? Libya: can a national court strip an international arbitration award of effect beyond its own borders, and what should award holders do now?

Contributors this fortnight

Paulina Schulte, Knightsbridge Group, United Arab Emirates
Jem Felicilda, Knightsbridge Group, United Arab Emirates
Idan Levy, MITIGATE Compliance & Risk Management, Israel
Abdulrahman Garoub, The Law Firm Of Majed Mohammed Garoub, Saudi Arabia
Dr. Bini Saroj, Khalifa Bin Huwaidan Alketbi Advocates & Legal Consultants, United Arab Emirates
Jakob Kisser, Kisser Legal, United Arab Emirates
Elena Sadovskaya, Inteliumlaw, United Arab Emirates

GLE Middle East: The Legal Developments Shaping Your Region This Fortnight